Table
of Contents
I.
Introduction
A.
Scope
of the Voluntary Compliance Program Guidance
B.
Benefits
of a Voluntary Compliance Program
C.
Application
of Voluntary Compliance Program Guidance
D.
The Difference
Between "Erroneous" and "Fraudulent" Claims To Federal Health
Programs
II.
Compliance Program Elements
A.
The Seven Basic Components of a Voluntary Compliance Program
B.
Steps for Implementing a Voluntary
Compliance Program
1.
Step One: Auditing and Monitoring
2. Step Two: Establish Practice Standards
and Procedures
3.
Step Three: Designation of a Compliance
Officer/Contact(s)
4. Step Four: Conducting Appropriate
Training and Education
5.
Step Five: Responding To Detected
Offenses and Developing Corrective Action Initiatives
6. Step Six: Developing Open Lines
of Communication
7.
Step Seven: Enforcing Disciplinary
Standards Through Well-Publicized Guidelines
C.
Assessing A Voluntary Compliance Program
III.
Conclusion & Footnotes
Appendix
of Additional Resources
Appendix
A: Additional Risk Areas
Appendix
B: Criminal Statutes
Appendix
C: Civil and Administrative Statutes
Appendix
D: OIG-HHS Contact Information
Appendix
E: Carrier Contact Information
Appendix
F: Internet Resources
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